UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
Plaintiff,
- v. -
LEBANESE CANADIAN BANK SAL, ELLISSA
HOLDING COMPANY, HASSAN AYASH EXCHANGE
COMPANY, CYBAMAR SWISS GMBH, LLC, STE

In addition, Ellissa Group SA, Ellissa
Holding, Ellissa Megastore, Ellissa Parc Cotonou, and Ellissa
Shipping, the latter three of which are located in Benin, were
designated (the Ellissa companies collectively, "Ellis sa
Holding").
?

c. Narcotics Trafficking in West Africa

During the last decade, drug trafficking
organizations have increasingly used countries along or near the
West African coast as trans-shipment hubs for importing massive
quantities of narcotics, particularly cocaine from South America,
to be later distributed in Europe or elsewhere within Africa.
Through a combination of privately owned aircraft and maritime
vessels, these organizations, predominantly based in Venezuela
and Colombia, have transported hundreds of tons of cocaine, worth
billions of dollars, to West African nations such as Benin,
Sierra Leone, and Togo.

50. The Ellissa Holding Company owns or controls
approximately nine companies in Lebanon, Benin and the DRC,
including the Ellissa Exchange, a money exchange based in
Sarafand, Lebanon; Ellissa Group SA, which owns a car park in
Cotonou, Benin, for receiving and selling used cars imported to
the Cotonou port; and Ellissa Shipping, which is principally
engaged in shipping used cars to Benin through the Cotonou port.
The Ellissa Holding Company is principally owned and controlled
by Jamal Mohamad Kharoubi and Ali Mohammed Kharroubi.

51. Wire transfers originating from the Ellissa
Exchange totaling approximately $61,747,524 were sent to United
States accounts for the purpose of purchasing or shipping cars
between in or about January 2007 and in or about January 2011.

G. Transfers from Ayash, Ellissa and Others to the United
States to Buy and Ship Used Cars

52. Between in or about January 2007 and in or about
January 2011, the Ayash Exchange and the Ellissa Exchange
originated approximately $203,269,615 or more in wire transfers
(the nExchange Funds") from'accounts held at LCB, Federal Bank,
BLOM, and MEAB (collectively, the nLebanese Banks") to bank
accounts in the United States for the purchase or shipping of
used cars.

53. Account holders other than Hassan Ayash Exchange

and Ellissa Exchange initiated wire transfers totaling at least
approximately $126,281,969 (the nNon-Exchange Funds") to bank
accounts in the United States for the purchase or shipping of
used cars. Some of the originators for these Non-Exchange. Funds
are discussed below, see ~ 77.
55. Between 2008 and 2010, used cars valued
collectively at over $1 billion were shipped from the United
States to Benin, including hundreds of millions' worth of used
cars purchased with funds from the Lebanese Banks.

65. Money couriers also transport millions of dollars
from Benin on commercial air flights.
Couriers travel on these
flights and carry the undeclared cash with them in order to evade
detection. For example, on December 9, 2010, three individuals
who had traveled on a flight from Benin were arrested at Charles
De Gaulle International Airport in Paris, France. The three were
en route to Beirut, Lebanon. They were discovered to be carrying
over $6.5 million in United States currency and €48,500. These
funds were not declared. One of the individuals was carrying a
business card for Ellissa Megastore, Ellissa's car lot in
Cotonou, Benin.

66. Cash is also commonly transported out of Benin
through the airport in Accra, Ghana,

approximately 210 miles from
Cotonou, Benin. The route from Cotonou to Accra passes through
Togo and its capital, Lome, on the Ghana border. The Ghanaian
Customs, Excise, and Preventive Services recorded approximately
$1.2 billion in declared United States currency imported across
the Lome border crossing in 2007 and 2008. Approximately $845
million of this was declared by Lebanese nationals.

67. From Accra, the cash is often flown to Beirut.

Hizballah security facilitates the receipt of cash flown into the
Beirut International Airport. For example, money couriers are
sometimes instructed over the public address system to deplane
first, and are escorted to private rooms in the airport where the
cash would be received.

Dated: New York, New York
December 15, 2011

PREET BHARARA
United States Attorney for the
Southern District of New York